ML20151N185

Insp Rept 50-425/88-35 on 880620-23.Violation Noted.Major Areas Inspected:Preoperational Testing,Insp Areas,Witnessing of Procedures Being Conducted & Review of Util Evaluation of Results of Tests of Approved,Completed Procedures

ML20151N185
Person / Time
Site:	Vogtle
Issue date:	07/25/1988
From:	Jape F, Szczepaniec A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151N176	List: ML20151N172 ML20151N177 ML20151N185
References
50-425-88-35, NUDOCS 8808080134
Download: ML20151N185 (5)

See also: IR 05000425/1988035

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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Report No.: 50-425/88-35

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Licensee: Georgia Power Company

t P. O. Box 4545 i

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Atlanta, GA 30302

l Docket No.: 50-425 License No.: CPPR-109 ,

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Facility Name: Vogtla 1 and 2

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Inspection Conduc d: Ju e 20-23, 1988

Inspector: i .,,~c- 7MINff

A.Szczepaniep vi ' Date Signed

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Accompanying Personnel: J. Zeiler .

Approved by: v40 h410 _,_ 7MJ7

F. Jape,' Chief

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Date Signed

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, Test Programs Section [/  !

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Engineering Branch  !

Division of Reactor $afety

SUMMARY

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Scope: This routine, announced inspection was conducted in the area of [

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preoperational testing. Inspection areas included the review of

issued test procedures, witnessing of procedures being conducted, and  !

the review of the licensee's evaluation of results of coinpisted, i

approved test procedures.

j Results: In general, the preoperationti test program is proceeding in acccrd-  !

i ance with regulatory requirements, However, during witnessing of  ;

a preoperational test a violation was observed. The violation is '

identified in Paragraph 3 as a failure to follow the test procedure J

in that specified prerequisites had not been signed off prior to the

associated test performance, as required by the procedure, i

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REPORT DETAILS

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1. Persons Contacted

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j Licensee Employees

) M. Bagale, Leau Test Supervisor

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T. Forehand, Lead Test Supervisor

• E. D. Groover, Quality Assurance Site Manager - Construction

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• S. M. Hall, Procedures Superintendent

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• H. M. Handfinger, Profect Startup Manager

'C. W. Hayes, Vogtle Quality Assurance Manager

• P. D. Rice, Vice President and Project Director ,

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Other licentee employees contacted during this inspection included i

craftsmen, engineers, operators, and administrative personnel.

NRC Resident Inspectors

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• C, W. Burger, Resident Inspector i

• R. Aiello, Resident Inspector

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• Attended exit interview

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2. Preoperational Test Procedures Review (70300) - On h 2

The inspector revfewed several licensee approved preoperational test

procedures either totally or in part including:

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2-3EG-01, Revision 0, Component Cooling Water (CCW) System

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2-3GK-08 Revision 0, Control Building Control Room HVAC Filtration

Units 2-1531-N7-001-000, 2-1531-N7-002-000 HEPA Filter and Charcoal  ;

Adsorber Tests 1

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2-3KE-03, Revision 0, Fuel Transfer System '

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2-4AB-04, Revision 0, Steam Generator Secondary Sioe Hydrostatic Test

The inspector verified that the procedures met Final S a fe.ty Analysis

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Repe-t (FSAR) requirements as stated in Chapter 14.2, Initial Test Program.

1 The procedures had proper management review and approval and the test i

objectives were clearly stated. The procedures included refarences to l

j; FSAR sections, drawings, vendor data, specifications, and administrative

controls of test performance, review, and approval. Test enuipment was

~j specified along with proper equipment calibration controls. Prerequisites

and initial test conditions were specified, including initial valve and  ;

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system lineups, electrical power and control requirements, and appropriate

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test performance aporovals. Step by step instructions appeared to be ,

complete to the extent nvcessary to assure that the test objectives were  !

met. Provisions were available for the verification and signoff of test t

items and for recording details of the conduct of the tests. Acceptance

criteria and limits were clearly identified and provisions for test

results review and approval were included.

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No violations or deviations were observed in this area.

3. Preoperation Test Procedure Witnessing (70312) - Unit 2

The inspector witnessed portions of the performance of Subsection 6.6 of

preoperational test 2-3EG-01, Revision 0, CCW System and portions of

preoperational test 2-4AB-04, Revision 0, Steam Generator Secondary Side

Hydrostatic Test. The portions of the tests witnessed by the inspector

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included the verification of the following:

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Appropriate revisions of the test procedures were available and in

use by the test personnel

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Test prerequisites were met

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Test equipment required by the procedures were calibrated

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Tests were performed as required by the approved procedures  !

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Criteria for interruption of testing and continuation of an interrupted

test were adhered to

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Significant events, unusual conditions, test discrepancies, and

j interruptions to testirig were documented

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Test personnel received the required training

Subsection 6.6 of preoperational test 2-3EG-01 involved the verification

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of pump operating characteristics of the Train "A" CCW system. Midway

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through tne test performance, the inspector reviewed portions of the

licensee's official test procedure and log. At this time, it was noted by

the inspector and a licensee Quality Assurance (QA) representative that

six steps in Section 5.0, Prerequisites and Initial Conditions, were not

signed-off as required. These steps were identified as 5.3, 5.4, 5.5,

5.8, 5.18 (for 480 Volt breaker 52-2N&l43), and 5.20 (for 480 Volt breaker

, 52-2NBJa7), and involved the Test Supervisor's review of items which may

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preclude or effect the performance of the test, authorization by the Lead

i Test Supervisor to perform the test, verification of the CCW surge tank

level, and verification of two 480 Volt AC breaker positions. Also,

further examination of the official procedure led to the discovery that

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three of the same prerequisite steps; 5.8, 5.18 (for breaker 52-2NBJ43),

! and 5.20 (for breaker 52-2NBJ47) had not been signed-off before the

performance of subsection 6.3, involving the testing of the CCW surge tank

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level controls, completed on June 14, 1988. The Test Supervisor stopped

the test 6nd informed the Lead Test Supervisor of the discrepancy. The ,

inspector observed that appropriate action was taken by the Lead Test

Supervisor to correct the affected steps in the procedure. The test

interruption and discrepancy was recorded in the test procedures log and '

the licensee generated an Operating Deficiency Report (ODR) to document

) and investigate the deficiency. The inspector observed no other discrep2 ,

ancies connected with the performance of this test. ,

This finding violates 10 CFR 50, Appendix B, Criterion V which requires ,

that activities affecting quality be prescribed by procedure and be 4

accomplished in awdance with those procedures.

This item is im * i t 'ed as violation 425/88-35-01, Failure to Follow

Preoperational is ! Frocedure 2-3EG-01, CCW System.

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The portions of preoperational test 2-4AB-04, Steam Generator Secondary

Side Hydrostatic Test observed was performed satisfactorily. Hcwever,

limited observation was possible due to a test interruption and delay

which occurred just before steam generato" 'ill operations when the steam

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generator water chemistry was analysed to e at of specified limits. The

test was resumed two days later after the ? generator water chemistry

was analysed to be within prescribed specifut. ions.

The inspector verified that the latest revision of the test procedures were l

available and in use. Initial conditions and test prerequisites were met. l

The portions of the test witnessed were performed as required by the test I

procedure and the test interruption was documented in the procedure test i

log.  !

4. Preoperational Test Procedure Result Evaluation Review (70562, 70400) -

Unit 2

A review was made of the results evaluations performed by the licensee for

selectc. 'est procedures that had been completed and approved. The

procedures selected were 2-300-03 Reactor Coolant System (RCS) Hydrostatic i

Test, 2-3PQ-01 120 Volt Vital AC (Class 1E) System, and 2-3BN-01 Refueling

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Water Storage Tank. The RCS Hydrostatic Test review is only partially

completed since the licensee has only completed a partial review and

approval. Final approval is pending approval of a Final Safety Analysis

Report (FSAR) change regarding test pump capacity.

For the procedures specified above, all changes were reviewed and found to

be approved in accordance with the pertinent administrative procedure.

Test changes were annotated in the procedures and none of the changes

reviewed were found to change the basic objectives of the test. The I

licensee was found to have specifically compared test results with the  !

established acceptance criteria, and cognizant engineering functions have j

evaluated the test results and have signified that the testing demonstrated '

that the system met design requirements. Data sheets were completed and

data, recorded where required, were within the acceptance criteria tolerances. ,

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Individual steps and data sheets were properly initialed and dated.

Independent audits by Quality Assurance pcrsonnel were performed during

test performance as required by administrative procedures. Those personnel

charged with the responsibility for review and acceptance of test results

have documented their reviews and acceptance of the data packages and the

evaluacions.

Some minor discrepancies were noted during the review. In each of the

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three procedure's review checklists, the lead test supervisor was found to

have signed the checklist before the cognizant test supervisor had signed

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the procedure coversheet. This is opposite the signing order required by

the Startup Manual Chapter 13, Paragraph 6.4. The 120 voit Vital AC

System test was also found to have the words "as applicable" qualifying

the signature of the reviewer on the procedure review checklist. The

licensee acknowledged that this had been done on other occasions also, due

to the extensive meaning the signature it understood to cover as understood

by the reviewer. For example, the signature is understood to verify a

rtquirement that all changes were current prior to commencing the test:

the reviewer felt he could not personally verify that fact during his

review after the test; therefore, the qualifying words were added. To do

away with the perceived need to do this, the licensee is contempliting a

change to the checklist format to clarify the signatures required.

l It was also observed during the review of the test data that licensee

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personnel other than those suthorized had entered data. This was identified

by the licensee and corrected during the result evaluation process. The

licensee then took additional action, including making charges to Startup

Manual Chapter 24 and issuing management memos to prevent recurrence.

The procedure results evaluations reviewed demonstrated the effectiveness

e of the licensee's result evaluation process in not only verifying test

results, but also in identifying discrepancies and taking appropriate

actions to ensure objectives of the test program are achieved.

5. Exit Interview

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The inspection scope and results were summarized on June 23, 19PO, with i

those persons indicated in Paragraph 1. The inspector described the areac  ;

inspected and discussed in detail the inspection results listed below.

The licensee did not identify as proprietary any of tne material provide ?

l to or reviewed by the inspectors during this inspection. Dissenting

comments were not received from the licensee.

Item Number Description and Reference

425/88-35-01 Viclation - Failure to follow test l

procedure - Paragraph 3

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